Legal Review and Analysis of In Re Issue Relating to Definition of Aravali Hills and Ranges 2025 INSC 1338
In-Short
Case: In Re: Issue Relating to Definition of Aravali Hills and Ranges (2025 INSC 1338): Supreme Court mandates a uniform definition for the Aravalis and a science-based Management Plan for Sustainable Mining, balancing ecological conservation against desertification with regulated resource use, while imposing a moratorium on new mining leases.
1. Heading of the Judgment
Case Name: In Re: Issue Relating to Definition of Aravali Hills and Ranges
Citation: 2025 INSC 1338
Court: Supreme Court of India
Jurisdiction: Inherent/Original Jurisdiction
Writ Petition (C) No.: 202 of 1995 (T.N. Godavarman Thirumulpad vs. Union of India and Others)
I.A. No.: 105701 of 2024
Date of Judgment: November 20, 2025
Judges: Chief Justice B.R. Gavai, Justice K. Vinod Chandran, and Justice N.V. Anjaria
2. Related Laws and International Instruments
The judgment primarily discusses and relies upon the following legal and international frameworks:
United Nations Convention to Combat Desertification (UNCCD): Ratified by India, it forms the international law basis for combating desertification, which is central to the Court's reasoning.
The Environment (Protection) Act, 1986: For notifying Eco-Sensitive Zones (ESZs).
The Wild Life (Protection) Act, 1972: Concerning Protected Areas, Tiger Reserves, and wildlife corridors.
The Forest (Conservation) Act, 1980: Pertaining to the conservation of forest land.
Government Policies:
National Action Plan to Combat Desertification and Land Degradation (2023).
Aravali Green Wall Project.
3. Basic Judgment Details
This judgment arises from the Supreme Court's continuous mandamus in the landmark case of T.N. Godavarman Thirumulpad vs. Union of India, concerning forest and environmental conservation. A specific issue regarding the lack of a uniform definition of the "Aravali Hills and Ranges" across the states of Rajasthan, Haryana, Gujarat, and Delhi was identified. This ambiguity was leading to unregulated and illegal mining, threatening the fragile ecosystem. The Court constituted a high-level committee to propose a uniform definition and a regulatory framework for mining in this ecologically critical region.
4. Core Principle and In-Depth Analysis of the Judgment
The core of this judgment is the resolution of the conflict between ecological conservation and regulated resource extraction in one of India's most ancient and fragile mountain ecosystems. The Court navigates this by establishing a science-based, precautionary framework for defining the area and managing activities within it.
A. The Central Issue: The Need for a Uniform Ecological Definition
The primary issue was the absence of a standard, scientific definition of what constitutes the "Aravali Hills and Ranges." Different states had their own interpretations, creating regulatory loopholes that facilitated illegal mining and ecological degradation. The Court recognized that effective conservation and regulation were impossible without first defining the geographical scope of the area to be protected.
Ecological Importance of the Aravalis:
The Court emphasized that the Aravali Range is one of the oldest fold mountains in the world. It acts as a critical "green barrier" against the eastward expansion of the Thar Desert into the fertile Indo-Gangetic plains. It is also a repository of rich biodiversity, hosts numerous wildlife sanctuaries and tiger reserves, and is crucial for aquifer recharge for several major river systems.India's International Obligations:
The Court grounded its reasoning in India's commitments under the United Nations Convention to Combat Desertification (UNCCD). It highlighted that Articles 4, 5, and 10 of the Convention obligate India to adopt long-term policy measures, strengthen laws, and implement action programmes to combat desertification and land degradation, with a focus on preventive measures for vulnerable lands like the Aravalis.
B. The Supreme Court's Analysis and Regulatory Framework
The Court analyzed the report submitted by the Committee constituted by the Ministry of Environment, Forest and Climate Change (MoEF&CC) and balanced it with the recommendations of the Central Empowered Committee (CEC) and the expert opinion of the Forest Survey of India (FSI).
Acceptance of the Committee's Definition:
The Supreme Court accepted the technical definition proposed by the Committee. This definition is based on specific topographical criteria:
Aravali Hills: Any landform in Aravali districts with an elevation of 100 meters or more from the local relief, including the entire landform within the lowest contour line.
Aravali Range: Two or more such hills located within 500 meters of each other, including the area between them.
This definition was preferred as it was argued to include a larger area under protection compared to the older FSI definition.The Crucial Directive for a Management Plan for Sustainable Mining (MPSM):
While accepting the definition, the Court issued its most significant directive. It ordered the MoEF&CC to prepare a Management Plan for Sustainable Mining (MPSM) for the entire Aravali range through the Indian Council of Forestry Research and Education (ICFRE), on the lines of the plan prepared for the Saranda forest in Jharkhand.
The MPSM is mandated to:
Identify areas where mining can be permitted, areas that are ecologically sensitive and must be declared "inviolate" (no-mining zones), and areas prioritized for restoration.
Incorporate a thorough analysis of cumulative environmental impacts and the ecological carrying capacity of the region.
Include detailed post-mining restoration and rehabilitation measures.
This ensures that future mining, if any, is based on a scientific assessment of the ecosystem's resilience and not merely on political or commercial considerations.Balancing Act: No Complete Ban on Existing Mining:
The Court consciously avoided imposing a complete ban on existing legal mining activities. It relied on its precedent in State of Bihar vs Pawan Kumar (2022) 2 SCC 348, which held that a total ban often fuels illegal mining, creates mafias, and leads to criminalization. Instead, it allowed existing legal mines to continue operating under strict compliance with the Committee's recommended safeguards, while imposing a moratorium on the grant of new mining leases until the MPSM is finalized.
5. Final Outcome of the Judgment
The Supreme Court issued the following final directions:
Accepted the uniform definition of Aravali Hills and Ranges as recommended by the Committee.
Accepted the recommendations for prohibiting mining in core/inviolate areas (like Protected Areas, ESZs, tiger corridors, wetlands, etc.) and for regulating sustainable mining.
Directed the MoEF&CC to prepare an MPSM through ICFRE for the entire Aravali range to scientifically zone the landscape for conservation and regulated mining.
Imposed a Moratorium on the grant of any new mining leases until the MPSM is finalized.
Permitted existing legal mining operations to continue, subject to strict adherence to the regulatory safeguards prescribed by the Committee.
6. (MCQs) Based on the Judgment
MCQ 1: What is the primary scientific reason, as emphasized by the Supreme Court in In Re: Aravali Hills (2025 INSC 1338), for the urgent conservation of the Aravali Range?
a) To promote tourism and recreational activities.
b) To act as a green barrier preventing the eastward spread of the Thar Desert.
c) To provide a new source of rare minerals for the country.
d) To serve as the primary location for new urban development.
MCQ 2: As per the Supreme Court's judgment, what must be completed before any new mining leases can be granted in the Aravali Hills and Ranges?
a) A public referendum in the affected states.
b) The submission of a report by the Central Empowered Committee (CEC).
c) The preparation and finalization of a Management Plan for Sustainable Mining (MPSM) by ICFRE.
d) The approval of the state legislatures of Rajasthan and Haryana.
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